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There’s already a classification system in place used by researchers (https://en.wikipedia.org/wiki/Nova_classification), but I imagine it has to be translated into legalese.
Also, according to that classification system, a PB&J wouldn’t necessarily be a UPF. You could use whole grain bread with no additives, jam made using raw sugar or honey and no other additives, and peanut butter with no additives.
Key factors to the Nova classification system seem to be whether it was made industrially and requires substantial processing, and the amount of additives, and whether those additives are heavily processed themselves.
My concern is that some of these "additives" could just be harmless preservatives, dyes, or even lab synthesized ingredients that are usually naturally occuring through some non industrial method, but they add them a different way because it's cheaper at scale.
Not saying it's the same but it gives me similar pause and concern as the the "natural dyes" initiative by RFK. The natural dyes are literally just the same chemicals just gotten from "natural" means rather than synthesized in a lab.
Another example is the fear mongering against high fructose corn syrup in the 00's when it's literally broken down into the same thing as sugar in your body before it's used. The only difference between it and sugar, even down to flavor, is that it was created in a lab from corn because it was cheaper because of government subsidies.